Courses 2009 - 2010

LAW T 515 International Taxation I

Credits: 3

A detailed and thorough analysis of principles relating to "inbound" investment in the U.S., including concepts relating to effectively connected income (and other rules relating to source of income), issues raised by tax treaties such as what constitutes a "permanent establishment", the anti-treaty shopping rules, the branch profits tax (§884), withholding on receipts of nonresident aliens (including classification issues relating to nonresident alien status), and rules relating to taxation of foreign investment in U.S. real property.